"Alternatives Analysis" w/ California DTSC

Alternatives Analysis, California style

The California Department of Toxic Substances Control (DTSC) is hosting a forum for the development of better "Alternatives Analysis." This means they want community feedback regarding tools, methodologies and frameworks used in analyzing alternative chemicals for hazard and toxicity risks.

This event is particularly of interest for manufacturers and distributors whose supply chain passes through California. Given the recent draft of California's "Safer Chemicals" legislation — not to mention California Prop 65
— how alternative analysis are approached and handled may have an effect on the materials you use (or discontinue) down the road.

DTSC says it is currently developing guidelines for conducting chemical / material alternatives analysis (AA) pursuant to AB 1879, and that October's two day public meeting will feature a DTSC presentation and stakeholder input on alternatives analysis (AA) tools, methodologies and frameworks.

At this stage this is something to know about and keep an eye on. It's something to attend only if your quality and compliance backbone reports that these meetings can have a significant impact on the materials your business uses, buys or sells
— or plans to in the future.

** Legal aspect: California Green Chemistry Initiative alternatives analysis statutory requirements
AB1879 – Sec 25253
• (a)(1) Establish a process for evaluating chemicals of concern in consumer products, and their potential alternatives, to determine how best to limit exposure or to reduce the level of hazard posed by a chemical of concern…”
• (a)(2) Establish a process that includes an evaluation of the availability of potential alternatives and potential hazards posed by those alternatives, as well as an evaluation of critical exposure pathways